RESTRICTIVE WYOMING BALLOT ACCESS BILL KILLED
On February 28, Wyoming State Senator Tara Nethercott, the Majority Leader of the Senate, exercised her power to kill HB 173, the bill that would have severely injured ballot access for independent candidates. She did this by not allowing the bill to receive a vote on the Senate floor.
The bill would have increased the number of signatures from 2% of the last vote, to 3% for statewide office, and 5% for legislative and county offices. Also, it would have moved the petition deadline from late August to early June, and furthermore required independent candidates to file a declaration of candidacy in May. Already Wyoming had the most severe requirements of any state, in relation to presidential elections, on a percentage basis. No other state requires a presidential candidate running outside the major parties to submit a petition greater than 2% of the last vote, when the easiest method in each state is compared.
The bill would have given Wyoming the earliest deadline of any state for a presidential candidate running outside of the two major parties to declare his or her candidacy. Legislators in the House and on the Senate Committee ignored the U.S. Supreme Court decision Anderson v Celebrezze, even though that decision was brought to their attention.
The bill had passed the Wyoming House by a vote of 49-11. Then it had passed the Senate Elections and Political Subdivisions Committee by a vote of 4-1.
Chuck Gray, the Secretary of State, strongly supported the bill. No Wyoming news media expressed any opinion about the bill, and gave it very little publicity.
Leaders of the state Republican Party had issued a statement of support for the bill on February 27, claiming the bill would enhance “election integrity”. But Senator Nethercott was not intimidated, and she killed the bill.
This outcome was only possible because a Libertarian Party-connected political consultant, Apollo Pazell, has cultivated close relations with some members of the Wyoming Senate, including Senator Nethercott.
This incident shows the need for leaders of minor parties to cultivate relationships with state legislators. In the United States, unlike other democracies, there is no consensus that minor parties and independent candidates should be allowed to participate in elections. Minor parties and independent candidates must deal with state legislatures to protect their ability to run.
NEW JERSEY FUSION BAN UPHELD
On February 26, a New Jersey Superior Court, Appellate Division, upheld New Jersey’s ban on fusion. The ban prohibits two political parties from jointly nominating the same candidate. Fusion was once permitted in every state, but was banned in most states decades ago. In New Jersey, it was banned in 1922. The case is In re Tom Malinowski Petition for Nomination, Mercer County, A-3542-21. The Plaintiffs will appeal to the State Supreme Court.
The judges wrote that the state interest is “to prevent fraud, ensure public confidence in the integrity of the electoral process, and to enable voters to cast their ballots in an orderly fashion.” There is no elaboration.
The judges cite decisions from the state courts of other states that also ruled against fusion, but they fail to mention the 1912 decision of New York’s highest state court that said the New York Constitution requires that fusion be permitted.
The New Jersey decision admits that the New Jersey Constitution sometimes has more protection for freedom of association, and for voting rights, than is contained in the U.S. Constitution. But the New Jersey judges wouldn’t let that influence the outcome in this case. The U.S. Supreme Court ruled in 1997 that the U.S. Constitution doesn’t protect fusion.
The plaintiffs include the Moderate Party, which wanted to nominate Tom Malinowski for U.S. House in the 2022 election, even though he was also a Democratic Party nominee. The plaintiffs had many amicus curiae on their side, including the ACLU, the Brennan Center, twelve political science and law professors, five former members of Congress (including Dick Gephardt, a former Majority Leader), Cato Institute, the New Jersey Libertarian Party, and the Rainey Center. The decision acknowledges the existence of all these amici, but doesn’t grapple with the points made in those briefs. It says if the plaintiffs want fusion, they are free to lobby the state legislature.
The only amicus on the side of the state was filed by the New Jersey Republican Party.
The decision is by Judge Robert J. Gilson and is also signed by Judges Lisa A. Firko and Lorraine M. Augostini. Gilson and Firko are appointees of Governor Jon Corzine, a Democrat. Judge Augostini is an appointee of Governor Chris Christie, a Republican.
BALLOT ACCESS BILLS
Alabama: on March 5, the House Constitution, Campaigns & Electionis Committee passed HB 258. It moves the midterm primaries from the fourth Tuesday in May to the second Tuesday in May. That automatically moves the petition deadline for new parties and independent candidates in midterm years two weeks earlier.
Arizona: on February 19, the Senate Federalism, Military Affairs & Elections Committee defeated SB 2844. It would have made it impossible for two independent candidates running for the same office to both be on the general election ballot. The vote was unanimous. It would have provided that if two independents running for the same office qualified, there must be an “independent primary”.
Arizona(2): on March 5, the House passed HCR 2057. It says that initiatives need the signatures of 10% of the registered voters in each county. Currently initiativesw need 10% of the registered voters but the signatures can be from anywhere in the state. Arizona is in the Ninth Circuit. In 2003, the Ninth Circuit struck down Idaho’s county distribution requirement, and Idaho’s requirement was more lenient and did require signatures from every county.
Arizona(3): on February 19, the House Federalism, Military Affairs & Elections Committee defeated HB 2705 by 3-4. It would have made it legal for candidates to combine signatures from more than a single county on a petition sheet.
Florida: the omnibus election law bill that had been introduced in the special session earlier this year contained a provision lowering candidate filing fees. But that bill, HB 21a, did not pass during the special session. The regular session has now begun, and again there is an omnibus election law bill, SB 1414 and HB 1205.
Unfortunately, these new bills don’t have any provision for lowering the filing fees. Florida has the highest filing fees of any state. They are twice as high as the second highest state. The fee to run for Congress, for members of a major or minor party, is over $10,000.
Hawaii: on March 4, HB 134 passed the House. It lets completed petitions be filed electronically. Although this is not the same as permitting signatures to be signed electronically, it still eases the procedure. Only three Representatives voted “no.”
Iowa: both bills to ease ballot access made no headway, and the deadline for a bill to have moved ahead has now passed, so both bills are dead. SB 68 would have moved the deadline for non-presidential independent candidate petitions, and petitions for the nominees of unqualified parties, from March to August. In 2022, a federal court had struck down the March petition deadlines, so all the bill would have done is update the language of the election code to actual policy. SB 70 would have eased the definition of a qualified party from a group that polled 2% for President or Governor to 2% for any statewide office.
Minnesota: on March 13, the House passed HF 66. It sets petitioning periods for independent candidates, and the nominees of unqualified parties, for special elections. It says the Secretary of State must allow at least six days for such petitions. Current law lets the Secretary of State set the petitioning period, and he has recently sometimes allowed only one day to collect 500 signatures for legislative candidates.
Mississippi: on March 5, the Senate passed HB 293, which moves the even year midterm primaries from June to March. That means the deadline to qualify a new party moves from February to January in midterm years.
Although the House had already passed the bill, it is still not passed, because the versions in each house differ. A conference committee will work on the bill.
North Dakota: on February 24, the House defeated HB 1245. It would have repealed the ban on paying initiative circulators on a per-signature basis. The vote was 29-64.
North Dakota(2): on February 25, the House defeated two bills that would have made it more difficult for candidates to get on a primary ballot. Currently, candidates get on the primary ballot automatically if they show substantial support at a party meeting, and if they don’t, they can petition. HB 1446 would have required all primary candidates to submit a petition. It lost 32-58. HB 1424 would have eliminated the petition alternative. It lost 3-86.
South Dakota: on March 10, the legislature passed HB 1169. It requires initiatives that would change the state Constitution to collect the signatures of 5% of the last gubernatorial vote in each of the state’s 35 legislative districts.
Utah: on March 7, HB 193 died because it had not made any headway before the deadline. It would have decreased the number of signatures to get on a primary ballot for candidates who hadn’t shown substantial support at a party meeting.
West Virginia: seven Republican legislators have introduced HB 2608. It would require independent candidates and the nominees of unqualified parties to file a declaration of candidacy in the second Monday of January. The legislators seem unaware that a virtually identical West Virginia law was struck down in U.S. District Court in 2016, in Daly v Tennant, 216 F.Supp.3d 699 (s.d.). The state did not appeal. The bill has made no headway since it was introduced in February.
ARKANSAS BILLS TO HOBBLE INITIATIVE PETITIONING PROCESS
The Arkansas legislature is in the process of creating unprecedented restrictions on the petitioning process. Although the bills only relate to initiative petitions, in the future the same hurdles might be applied to petitions to recognize new parties and independent candidate petitions.
SB 208 requires that petition signers must show their photo ID to the circulator before signing the petition. If the circulator lets someone sign before viewing the ID, the circulator is guilty of a misdemeanor. No state has ever before had a law like this. Governor Sarah Huckabee Sanders signed it on March 4.
SB 207 requires the circulator to tell any potential signer that petitioin fraud is a crime. If the circulator doesn’t do this, he or she is guilty of a misdemeanor. It was signed on February 27.
SB 210 requires the circulator to read the summary of the initiative to any potential signer. Sometimes the summary is long and detailed, and can require as much as five minutes to be read aloud. This bill has passed the Senate and will probably pass the House soon. As with the other bills, if the circulator doesn’t obey this law, he or she has violated the criminal law.
SB 209 says that if a petitioner is found to have committeed any crimes, none of the signatures he or she obtained are valid. This bill has passed both houses but is in a conference committee so it hasn’t passed yet.
SB 211 says that when a petitioner submits his or her first batch of signatures, the petitioner must then file an affidavit with the Secretary of State, and can’t resume work until it has been processed. It was signed March 3.
The author of these bills is Senator Kim Hammer (R-Benton).
LAWSUIT NEWS
California: on February 21, an amended Complaint was filed in Peace & Freedom Party v Weber, n.d., 3:24cv-08308. This is the lawsuit that challenges the top-two system. The main reason for the amended Complaint was so that the American Solidarity Party could be added as a co-plaintiff.
Florida: on March 11, the Eleventh Circuit upheld the constitutionality of the state’s closed primary. Polelle v Florida Secretary of State, 22-14031. An independent voter had sued, arguing that because he can’t vote in Republican primaries, and because the Republican Party always wins every election in his county (Sarasota), he is effectively disenfranchised. The decision was written by Judge Rosin Rosenbaum, an Obama appointee. It is also signed by Judge Nancy Abudu (Biden) and Judge Gerald Tjoflat (Ford). They said the U.S. Supreme Court already settled this issue in 1976, when it summarily affirmed a case from Connecticut, Nader v Schaffer. The issues were the same in that case. The plaintiff in that case had been Nathra Nader, father of Ralph Nader.
Georgia: on December 16, 2024, the Georgia Libertarian and Green Parties filed a new lawsuit against the campaign finance law that lets individuals donate more money to a Republican or Democratic candidate for Governor or Lieutenant Governor than to any other candidate for those two offices. Libertarian Party of Georgia v Carr, .d., 1:24cv-05763. A similar lawsuit had been dismissed on standing grounds, so the new lawsuit was structured to avoid that problem.
Indiana: the U.S. Supreme Court will consider whether to hear Indiana Green Party v Morales, 24M68, at its March 21 conference. This is the ballot access lawsuit. In order for the Court to take this case, it would first need to excuse the filing for being late, even though that was the Court clerk’s own mistake.
New York: on February 24, the U.S. Supreme Court refused to hear Kennedy v Cartwright, 24-646. This was Robert F. Kennedy, Jr’s ballot access case. The issue was whether he should have been barred from the ballot because he gave a residence address with which he had little connection.
New York(2): on February 24, the U.S. Supreme Court refused to hear Upstate Jobs Party v Kosinski, 24-503. The issue was the state’s campaign finance law, which lets individuals give more money to the nominee of a qualified party than to an independent candidate or the nominee of an unqualified party.
Texas: the U.S. Supreme Court will consider whether to hear Miller v Nelson, 24-854, at its March 21 conference. The issue is the various ballot access laws that realistically block any statewide petitions unless the party or candidate has at least $1,000,000 to spend on the petition drive.
National: the U.S. Supreme Court is being asked by the Republican National Senatorial Committee to rule that parties can spend as much money as they wish to help their own nominees, even if the party coordinates with the nominee. Current law lets parties spend unlimited amounts only if they don’t coordiniate with the nominee. National Republican Senatorial Committee v FEC, 24-3051.
Amicus curiae briefs have already been filed in support of the Republican Party by fourteen states, the Chamber of Commerce, the Institute for Free Speech, the Republican Governors Association, U.S. Senator Mitch McConnell, and the Georgia Republican Party.
Even though the lawsuit, if successful, would help the Democratic Party, no Democratic group or individual has filed anything in support of the case. No minor party has filed anything in this case either, even though in the past the Libertarian Party fought the existing law.
MINOR PARTY MEMBERS WHO RAN IN CALIFORNIA TOP-TWO PRIMARIES WITH
BOTH A DEMOCRAT AND A REPUBLICAN ALSO RUNNING IN 2024
| DATE | CANDIDATE | PARTY | OFFICE | RANK | VOTE % |
| 3/5/2024 | Laura Garza | Socialist Workers | U.S. Senate | 10th of 27 | .47% |
| 3/5/2024 | Gail Lightfoot | Libertarian | U.S. Senate | 13th of 27 | .46% |
| 3/5/2024 | Mark Ruzon | American Solidarity | U.S. Senate | 23rd of 27 | .18% |
| 3/5/2024 | Forrest Jones | American Independent | U.S. Senate | 24th of 27 | .18% |
| 3/5/2024 | Don J. Grundmann | Constitution | U.S. Senate | 27th of 27 | .09% |
| 3/5/2024 | Chris Richardson | Green | U.S. House 6 | 6th of 6 | 1.80% |
| 3/5/2024 | Joe Dehn | Libertarian | U.S. House 17 | 5th of 5 | 1.56% |
| 3/5/2024 | Sean Dougherty | Green | U.S. House 19 | 3rd of 3 | 6.41% |
| 3/5/2024 | William Patterson | Peace & Freedom | U.S. House 28 | 3rd of 4 | 2.21% |
| 3/5/2024 | Jose Castaneda | Libertarian | U.S. House 28 | 4th of 4 | 1.99% |
| 3/5/2024 | Aaron Reveles | Peace & Freedom | U.S. House 34 | 4th of 5 | 3.96% |
| 3/5/2024 | Jing Chao Xiong | Common Sense | State Senate 11 | 4th of 4 | 3.82% |
| 3/5/2024 | Michael Oxford | Libertarian | State Senate 17 | 4th of 4 | 2.06% |
| 3/5/2024 | Kevin Olmar Martinez | Peace & Freedom | Assembly 6 | 10th of 10 | 1.80% |
| 3/5/2024 | Andre Sandford | American Independent | Assembly 18 | 2nd of 4 | 5.32% |
| 3/5/2024 | Bob Goodwyn | Libertarian | Assembly 26 | 5th of 6 | 2.98% |
| 3/5/2024 | Shannel Pittman | Green | Assembly 52 | 9th of 10 | 1.48% |
| 3/5/2024 | Babar Khan | Peace & Freedom | Assembly 71 | 3rd of 3 | 2.59% |
MINOR PARTY MEMBERS WHO RAN IN WASHINGTON TOP-TWO PRIMARIES
WITH BOTH A DEMOCRAT AND A REPUBLICAN ALSO RUNNING IN 2024
| DATE | CANDIDATE | PARTY | OFFICE | RANK | VOTE % |
| 8/6/2024 | Henry Clay Dennison | Socialist Workers | U.S. Senate | 11th of 11 | .40% |
| 8/6/2024 | Andre Stackhouse | Green | Governor | 10th of 28 | .61% |
| 8/6/2024 | Michael DePaula | Libertarian | Governor | 19th of 28 | .20% |
| 8/6/2024 | Damond Townsend | No Labels | Secretary of State | 4th of 4 | 7.31% |
| 8/6/2024 | Jason Call | Green | U.S. House 2 | 7th of 8 | 3.53% |
| 8/6/2024 | Charles Schaefer | Libertarian | State Senate 33 | 3rd of 3 | 6.73% |
| 8/6/2024 | Justin Franks | Libertarian | State Representative 19-2 | 3rd of 3 | 3.43% |
This chart lists all minor party members who ran in 2024 top-two elections for federal and state office, and for which such minor party candidates had at least one Republican and one Democratic opponent on the primary ballot. California and Washington are the only two states that have ever had top-two systems, so the chart is limited to those two states.
Similar charts for past top-two elections were in these older issues of B.A.N.: June 2013, July 2014, October 2016, September 2020, and September 2022.
Combining the data from all six charts reveals that minor party candidates for federal and state office have run in 233 regularly-scheduled top-two primaries in which such minor party candidates had a Democratic opponent and a Republican opponent on the primary ballot. Out of those instances, only one minor party candidate ever placed first or second. That was in 2024, in the California Assembly race, District 18. An American Independent Party member placed second. He had two Republican opponents and one Democratic opponent on the primary ballot.
Top-two primaries were first used in Washington in 2008 and California in 2011. Washington is somewhat more permissive than California. Washington lets all candidates choose any partisan label they wish, as long as it is not obscene and not too long. Also, Washington has write-in space on all ballots, primary and general. California bans write-ins for top-two offices in November. Also, California will not print any partisan label on the ballot, except for the members of qualified parties. Members of non-qualified parties must have “Party Preference: none” on the ballot.
2026 PETITIONING FOR STATEWIDE OFFICES
This petitioning chart shows which parties (other than the Republicans and Democrats) are on the statewide ballot in each state for 2026. * means the entry changed since the last issue. # means that a candidate who uses the independent procedure may choose a short partisan label other than just “independent.”
| Party sigs | Indp sigs | LIB’T | GREEN | CONSTIT | FORWRD | Pty due | Indp due | |
| Alabama | 42,459 | 42,459 | 0 | 0 | 0 | 0 | May 26 | May 26 |
| Alaska | (reg) 5,000 | Pay fee | already on | 1,539 | 794 | ? | May 4 | June 1 |
| Arizona | 34,127 | (est) 48,000 | already on | already on | 0 | 0 | Nov 28, 25 | May 6 |
| Arkansas | 10,000 | 10,000 | *100 | 0 | 0 | 0 | April 28 | May 31 |
| Calif. | (reg 75,000 | 65 | already on | already on | *189 | *1,200 | Dec 31 25 | March 6 |
| Colorado | 10,000 | 8,000 | already on | already on | clready on | *312 | Jan 9 | July 9 |
| Conn. | no procedure | 7,500 | can’t start | can’t start | can’t start | can’t start | – – | Aug 10 |
| Del. | (reg) 780 | 7,800 | already on | already on | 235 | ? | Aug 25 | July 15 |
| D.C. | no procedure | 3,000 | can’t start | already on | can’t start | can’t start | – – | Aug 5 |
| Florida | be organized | 0 | already on | already on | already on | already on | Apr 24 | Apr 24 |
| Georgia | 72,680 | 70,083 | can’t start | can’t start | can’t start | can’t start | July 14 | July 14 |
| Hawaii | 861 | 25 | already on | already on | 0 | 0 | Feb 20 | June 2 |
| Idaho | 18,102 | 1,000 | already on | 0 | clready on | 0 | Aug 30 | March 21 |
| Illinois | no procedure | 25,000 | can’t start | can’t start | can’t start | can’t start | – – | May 25 |
| Indiana | no procedure | 36,944 | already on | can’t start | can’t start | can’t start | – – | June 30 |
| Iowa | no procedure | 3,500 | 0 | 0 | 0 | 0 | – – | Aug 14 |
| Kansas | 20,180 | 5,000 | already on | 0 | 0 | 0 | June 1 | Aug 3 |
| Kentucky | no procedure | 5,000 | can’ t start | can’t start | can’t start | can’t start | – – | Aug 11 |
| Louisiana | 1,000 + 5,000 | 5,000 | 7,538 | 16,753 | 6,409 | 389 | June 17 | June 17 |
| Maine | (reg) 5,000 | 4,000 | already on | already on | 0 | 0 | Jan 2 | June 1 |
| Maryld. | 10,000 | 10,000 | *1,300 | already on | 0 | 0 | Aug 3 | Aug 3 |
| Mass. | (reg) 45, 500 | 10,000 | 15,672 | 3,545 | 289 | 35 | Feb. 1 | July 28 |
| Michigan | 44,618 | 12,000 | already on | already on | already on | 0 | July 16 | July 16 |
| Minn. | 163,621 | 2,000 | can’t start | can’t start | can’t start | can’t start | May 2 | June 2 |
| Miss. | be organized | 1,000 | already on | already on | already on | 0 | March 1 | Feb. 2 |
| Missouri | 10,000 | 10,000 | already on | 0 | 0 | 0 | Muly 27 | July 27 |
| Montana | 5,000 | 15,985 | already on | 0 | 0 | 0 | March 2 | May 26 |
| Nebraska | 6,726 | 4,000 | already on | 0 | 0 | 0 | Aug 3 | Sept 1 |
| Nevada | 14,271 | 250 | already on | 0 | already on | *100 | May 12 | May 12 |
| N.Hamp | 24,375 | 3,000 | 0 | 0 | 0 | 0 | Aug 4 | Aug 4 |
| N Jersey | no procedure | 2,000 | 0 | 0 | 0 | 0 | – – | June 2 |
| N Mex | 3,560 +14,246 | 14,246 | 0 | 0 | 0 | 0 | June 25 | June 25 |
| N York | no procedure | 45,000 | can’t start | can’t start | can’t start | can’t start | – – | May 26 |
| No Caro | 13,979 | 83,874 | already on | already on | ??? | *3,500 | May 17 | March 3 |
| No Dak | 7,000 | 1,000 | 0 | 0 | 0 | 0 | April 6 | Aug 31 |
| Ohio | 57,678 | 5,000 | already on | 0 | 0 | *21,000 | July 1 | May 4 |
| Okla | 34,599 | 0 | already on | 0 | 0 | 0 | March 2 | April 10 |
| Oregon | 29,294 | 22,445 | already on | already on | already on | 0 | Aug 11 | Aug 11 |
| Penn. | no procedure | 5,000 | can’t start | can’t start | can’t start | can’t start | Aug 3 | |
| R.I. | 17,884 | 1,000 | 0 | 0 | 0 | 0 | Aug 3 | July 10 |
| So.Car. | 10,000 | 10,000 | already on | already on | already on | already on | May 3 | July 15 |
| So.Dak. | 3,502 | 3,502 | already on | 0 | 0 | 0 | July 1 | April 28 |
| Tenn | 43,498 | 25 | in court | 0 | 0 | 0 | Aug 5 | April 2 |
| Texas | 71,030 | 71,030 | already on | already on | can’t start | can’t start | May 26 | June 25 |
| Utah | 2,000 | #1,000 | already on | 0 | clready on | already on | Nv 30 ‘25 | June 15 |
| Vermont | be organized | 500 | already on | 0 | 0 | 0 | Dec 31 ‘25 | Aug 6 |
| Virginia | no procedure | 10,000 | can’t start | can’t start | can’t start | can’t start | — | June 16 |
| Wash. | no procedure | 0 | can’t start | can’t start | can’t start | can’t start | – – | May 8 |
| W.Va. | no procedure | 7,478 | already on | already on | already on | 0 | – – | Aug 3 |
| Wisc. | 10,000 | 2,000 | already on | already on | already on | can’t start | April 1 | June 1 |
| Wyoming | 5,201 | 5,201 | already on | 0 | already on | 0 | June 1 | Aug 24 |
| #ON | 29 | 17 | 12 | *3 |
UTAH STATE SENATOR REGISTERS AS A MEMBER OF THE FORWARD PARTY
On March 7, Utah State Senator Daniel Thatcher changed his registration from “Republican” to “Forward”. He was first elected to the Senate in 2010, and is up for re-election in 2026.
He is the first state legislator to be a registered member of the Forward Party. Other nationally organized third parties that have had at least one state legislator, in the period since 1968, have been the American Party, the Libertarian Party, the Reform Party, the New Alliance Party, the Green Party, and the Constitution Party.
PIRATE PARTY SETS NATIONAL CONVENTION
The Pirate Party will hold its 2025 national convention on July 4, 2025, in San Francisco. It will encourage members to run for office.
The Pirate Party is organized in dozens of countries and has shown strength in some of them. However, it has a very sparse record of appearing on the ballot in the United States. The only candidates who have appeared on a U.S. ballot, using the party name, have been state legislative candidates in Massachusetts and Wisconsin. The party ran Ethan Osborne for U.S. House in Kentucky in 2022, but his ballot label was “Independent.”
FEC PUBLISHES 2022 ELECTION RESULTS
The Federal Election Commission has finally published its book of congressional election results for 2022. The title of the book is “Federal Elections 2022.” It is 146 pages, and includes primary and general results. Anyone may receive a free copy by telephoning the FEC at 800-424-9530 and asking for a copy. The FEC has been publishing such books since 1980.
MICHIGAN CONSTITUTION PARTY NAME CHANGE HOPE
In 1992, Howard Phillips founded the U.S. Taxpayers Party. In 1999 it changed its name to the Constitution Party. Almost all of the state units that were already on the ballot sought permission from the state elections office to change its name within that state. The only state in which the party made that request, and the state refused, was Michigan.
As a result, the party in Michigan is always on the ballot under the old, obsolete name. Recently, the state unit in Michigan resolved that it will take legal action to force the Secretary of State to let it change its name.
Almost no state has any election law on the subject of whether a party can change its name. States that have let qualified parties change their name are Alabama in 1979, Alaska in 1972, Hawaii in 1978, Idaho in 1998, Kansas in 1972, Kentucky in 1983, Massachusetts in 1991, Minnesota in 1944, Missouri in 2000, New Mexico in 1979, New York in 1994, Oregon in 1993, Pennsylvania in 1993, South Carolina in 1993. Some of these states have allowed name changes many times, but the list above only includes the first time it was permitted.
Didn’t Apollo Pazell switch to the Liberal Party?
He is a registered Republican.
Party signature totals for New Hampshire should be listed as “can’t start” in the chart 2026 PETITIONING FOR STATEWIDE OFFICES. Petitions can only be circulated in the election year.
https://www.liberalpartyusa.org/our_board
Pazell is listed as secretary